Six financial institution regulatory agencies — The Office of the Comptroller of the Currency (“OCC”), Federal Reserve Board, the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Securities and Exchange Commission — recently released their final standards for assessing the diversity practices and policies of regulated entities.
As required by Section 342 of Dodd-Frank, the regulators are required to establish an Office of Minority and Women Inclusion (“OMWI”) at each of the six agencies. The OMWI is responsible for monitoring and assessing diversity activities in employment, management and business activities at the entities they regulate.
The agencies released the final standards to serve as a framework for regulated entities to develop and maintain policies and practices for:
- Organizational commitment to diversity and inclusion
- Workforce profile and employment practices
- Procurement and business practices for supplier diversity
- Practices to promote transparency of organizational diversity and inclusion
- Entities’ self-assessment
The regulators stressed that the each agency conducted its own discussions with depository institutions, industry trade groups, consumer advocacy groups and community representatives in developing the final standards. The regulators also considered more than 200 comments made after the proposed standards were published in 2013.
The final standards do not vary much from the proposed standards; however, regulators have added clarifying language in response to public commentary. For example, the final standards adopt the Dodd-Frank definition of “diversity,” which includes African-Americans, Hispanic Americans, Asian Americans, Native Americans and women, but allows for entities to adopt a broader definition if desired.
Adoption of the final standards is voluntary and the agencies will not evaluate a regulated entity’s adherence through examination or supervisory processes.
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